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FD 30186 · TONGUE RIVER RAILROAD COMPANY, INC.--RAIL CONSTRUCTION AND OPERATION--IN CUSTER, POWDER RIVER AND ROSEBUD COUNTIES, MONT.

Comment EI-20741

Received or sent (printed as 12/19/2014)

December 19, 2014 Daniel R. Elliott, Chairman Deb Miller, Vice Chair Ann D. Begeman, Board Member Surface Transportation Board 395 E. Street, SW Washington, DC 20423 RE: Impact Statement for Tongue River Railroad, Docket Number FD_30186_0 Request for: A Complete Study of Impacts of the Tongue River Railroad on Billings, Montana; A Public Hearing in Billings, Montana; and An Order for Increased Contributions from the Tongue River Railroad to mitigate impacts of its operations on Billings, Montana. Dear Chairman Elliott, Vice Chair Miller and Board Member Bergeman: The Surface Transportation Board is currently considering granting a license for the construction of the Tongue River Railroad in south central Montana. As part of the licensing process the Board has agreed to assess the impacts of the Tongue River Railroad on the existing rail system and the communities along that rail system. I would like to discuss the potential impact of the Tongue River Railroad on my community, Billings, Montana. I am Paul Van Tricht. I was born in Billings, Montana in 1944 and have lived in Billings most of my life. Billings is a community which is bisected by the Burlington Northern Santa Fe/Montana Rail Link Railroad. The proposed Tongue River Railroad links to this line. The sole purpose of the Tongue River Railroad is to transport coal from the planned Otter Creek Mine to the West Coast for shipment to Asia. The Burlington Northern Santa Fe/Montana Rail Link Railroad runs east to west through Billings. It divides the older parts of Billings into a “Northside” and a “Southside”. The principal road running north to south through Billings and connecting the Northside and the Southside is a four lane street, 27th Street. That street connects Highway 3 to Interstate 90 and is one of three exists from Interstate 90 to Billings. 27th Street is the major north/south thoroughfare in downtown Billings and connects downtown Billings to Interstate 90. That street which is technically part of Highway 3 and administered by the Montana Department of Transportation crosses the railroad at a street-rail grade crossing. Traffic is stopped on 27th Street each time a train comes through Billings. Since 2009 there has been a major increase in rail traffic through Billings. There has been increased general rail/intermodal traffic, increased coal export traffic from the Powder River Basin to the West Coast and increased crude oil-by-rail traffic through Billings. I travel from the Northside of Billings to the Southside of Billings on a daily basis using 27th Street. These trips are generally delayed at the rail crossing by train traffic. Every loaded coal train from the Otter Creek Mine to the West Coast and every empty coal train back to that mine will travel through Billings. Arch Coal, which owns the Otter Creek Mine and is a partner in the Tongue River Railroad along with BNSF, plans to mine about 200 million tons of coal a year from that mine. Based on the current size of coal trains that amount of coal translates to 16 additional coal trains coming through Billings each and every day; eight full coal trains going to the West Coast and eight empty coal trains returning from the West Coast. If the west coast coal ports are built many more coal trains from existing Powder River coal mines also can be expected to travel through Billings. These additional 16 coal trains to and from Otter Creek when added to existing rail traffic will create a “train wall” which will divide downtown Billings and block Highway 3. This division will result in many adverse impacts. For example, both Hospitals/ Emergency rooms in Billings a located on the Northside. People with medical emergencies in the Southside will be delayed in getting treatment by this train wall. The major city, county and federal offices and pubic safety facilities in Billings are located on the Northside. Responses to public safety emergencies in the Southside will be delayed by the train wall. The train wall will render 27th Street unusable as an exit from Interstate 90 to downtown Billings and for commerce between the Northside and Southside of Billings. Mitigating theses adverse impacts of increased rail traffic in Billings will be very, very costly. Just modernizing the traffic signals in downtown Billings to accommodate the increased railroad traffic will cost hundreds of thousands of dollars. There are other very expensive grade separation projects in Billings which will be required as a result of the increase rail traffic. It is my understanding that in past cases which presented major adverse community impacts created by new railroads the Surface Transportation Board has ordered the Railroad to contribute more than the normal 5% toward mitigating the impacts of the Railroad, e.g., new grade separation projects, and that these orders have been approved by Federal Courts. Therefore, I request that the Board issue an order requiring the Tongue River Railroad, which is owned by in part Burlington Northern Santa Fe and Arch Coal, increase the contributions that the Railroad make for grade separation projects needed in downtown Billings. What I have related is just my own limited personal observations. Therefore, I request that the Surface Transportation Board have a full detailed study of the impacts of the increased railroad traffic generated by the Tongue River Railroad. To aid the Board I request that it conduct a public information gathering hearing in Billings. To prevent undo delay I suggest the hearing be conducted by hearing officer from the Board’s Office of Environmental Analysis. Thank you for your consideration of my comments and requests. I will follow these comments with more detailed information. Sincerely Paul J.Van Tricht 1134 North 24th Street Billings, Montana 59101-0219 Ph: 406-371-5350 Email: pauljvantricht@gmail.com cc. Senator Testor, Senator Walsh, Congressman Daines, Congressman-elect Zinke, Governor Bullock, Montana Transportation Commission.

Submitted by: Paul Van Tricht · Billings, Montana

The Board publishes this comment in its environmental-comment table for this proceeding. It is quoted here as printed; nothing is inferred from it, and it states the commenter's own position in their own words, not this record's.

Permanent address docketyard.org/d/FD-30186/comment/EI-20741 · back to the docket sheet